Health and Safety
Executive / Commission
Carriage of dangerous goods
1. Regulation 53 is the basis for implementing ADR. Paragraphs as follows:
2. Depending on the case, these duties fall on the packer, loader, consignor and/or carrier. Marking and labelling of packages is the duty of packers and consignors. Placarding and marking of containers, multi-element gas containers (MEGC, definition in ADR 1.2.1), tank containers, portable tanks, vehicles etc is the duty of the loader, consignor and carrier. Documentation is the duty of the consignor and carrier.
3. Regulation 63(7) reiterates the carrier's duty to ensure that documentation is carried.
4. The relevant part of ADR is part 5. There are linked requirements in part 8, but they make it the carrier's duty to ensure that the "transport unit" carries the documents, placards etc. that are required by Part 5.
5. Chapter 5.1 contains the general provisions and covers:
6. These words mean something different, but in both cases refer to packages.
7. The details are to be found in the various sub-paragraphs within 5.2.1 and 5.2.2 respectively. This is highly prescriptive and includes special requirements for certain substances.
8. Size requirements are in 5.2.2.2.1.1. ADR 2007 permits some flexibility in labelling of refrigerated liquid gases (5.2.2.2.1.1), and also allows changes to the background colour of flammable gas labels for UN1011, 1075, 1965, and 1978 (5.2.2.2.1.6 (c)).
9. There is an additional requirement to display an orientation label for certain packages (5.2.1.9). ADR 2007 permits alternative colours (black or red) for the orientation arrows.
10. Working logically through the sections enables the requirements to be precisely determined.
11. The rules for combined supply and carriage labelling have been amended. In any event the carriage labelling has to be applied.
12. As with marking and labelling these words mean different things, and apply to vehicles and containers, MEGCs (multi element gas container - defined in ADR 1.2.1), tank containers, and portable tanks.
13. Placarding is the process of placing on the tank, container etc. the hazard diamonds referred to in column 5 of table A (analogous to labelling of packages). The precise details of sizes and so on are at 5.3.1.7. For small tanks or containers smaller placards can be used (5.3.1.7.3 - allows "package labels" to be used).
14. Placards have to be displayed as indicated in 5.3.1.2 to 5.3.1.6 according to the type of load.
15. Marking is the process of placing on the vehicle and the tank, container etc, the orange plates. See ADR 5.3.2.
16. ADR 2005 allows the familiar plain orange plate to be divided by a horizontal black line (5.3.2.2.1).
17. In all cases the plain orange plates for vehicles carrying packages are as described in ADR at 5.3.2.1.1. A plain orange plate is fixed at front and back of the “transport unit”. Note the extra requirement for vehicles carrying class 1 (explosives) and class 7 ((radio-active substances) to display placards (hazard diamonds) on both sides and the rear of the vehicle (ADR 5.3.1.5).
18. This is similar to the above but in this case the freight container should display relevant placards (hazard diamonds) on all four sides of the container.
19. ADR 2007 continues the requirement of Special Provision CV 36 (see 7.5.11 and table A column 18). This requires vehicles carrying packages of gases which could vitiate the atmosphere to be carried in open or ventilated vehicles /containers or if that is not feasible the cargo doors have to carry a suitable warning.
20. Different requirements apply to GB domestic journeys and international journeys. CDG 2007 (at regulation 91 and Schedule 7) require GB registered vehicles on GB domestic journeys to be marked with the familiar “Emergency Action Codes” (sometimes called “Hazchem codes”), and to include a telephone number for advice in the event of an emergency. This is usually in the form of a hazard warning panel, an example of which is shown in Schedule 7. This is in addition to the plain orange plate at the front of the vehicle. Note that paragraph 5(3) of schedule 7 allows the hazard warning panel not to be fire resisting for tanks made before 1 January 2005.
GB registered vehicle on GB domestic journey
21. Vehicles with tanks etc on international journeys carry the HIN (hazard identification number – sometimes called the Kemler code) in the pattern shown at ADR para 5.3.2.2.3. For example:
These are in addition to the placards (hazard warning diamonds) described at para 12 above.
22. Plates should be displayed at the rear and both sides, with a plain orange plate at the front. Where one substance only is carried it is permissible to display plates at front and rear only provided the front plate also carries the HIN code and UN Number. There is no requirement to display a telephone number. An international journey is described at ADR 1.1.2.4.
23. Chapter 5.4 of ADR covers this in the usual detail. The key requirements are that the documentation contains the following information (5.4.1.1):
24. New for ADR 2007 is that the first four items of information listed above must appear in that order. (ADR 5.1.1.1.1).There is no requirement for all information to be on one document. Where a vehicle has picked up loads from more than one consignor this would clearly not be possible.
25. There are special rules for wastes, salvage packagings, and empty uncleaned packaging etc (5.4.1.1.3 to 5.4.1.1.6). For more on empty uncleaned packaging and wastes see Common problems.
26. For empty tanks and bulk there are other rules about documentation in 5.4.1.1.6. See Common problems for a discussion of practical problems.
27. Where loads are being carried on domestic journeys under the limited load threshold (ADR 1.1.3.6 - more details in Main exemptions) the requirement to carry documentation is disapplied (except for explosives and radioactives). Details in regulation 26. The regulation 34/ ADR 1.4.2.1.1(b) requirement to furnish the carrier with documentation still applies.
28. Other special rules cover:
29. There are other rules for class 1 (explosives) class 2 (gases), class 4.1 (flammable solids etc.), class 5.2 (organic peroxides), class 6.2 (infectious substances) class 7 (radioactives). These are in ADR 5.4.1.2. The most likely to be met are those relating to gas mixtures where the composition of the mixture should be given (5.4.1.2.2(a)).
30. The language should be that of the forwarding country and one of English, French or German if not already on the document (5.4.1.4.1). This means that, especially for international journeys, the documents may not be in English and that is one reason why the layout of the information referred to in 5.4.1.1.1 is important.
31. Emergency information is a separate consideration from documentation and is covered in Crew and vehicle.